Chamber 92 | VASP Licensing & Virtual Asset Legal Services in Pakistan

Chamber 92

VASP Licensing & Virtual Asset Legal Services in Pakistan

Complete legal support for Virtual Asset Service Providers. PVARA applications, Regulatory Sandbox, No Objection Certificate, VASP Licence, Virtual Assets Act 2026 compliance, corporate setup and ongoing regulatory advisory.

Serving Lahore · Islamabad · Karachi · Sahiwal · Rawalpindi · Faisalabad · Multan · Peshawar · Quetta
Also: Kasur · Okara · Depalpur · Sheikhupura · Nankana Sahib & surrounding regions

📞 +92 323 8453223

📋 Click on a Topic to Jump to Details

📖 Licensing Framework Overview 🗂️ Types of Licences ✅ Licensing Requirements 🛤️ Your Path to Licensing 🧭 Which Route Applies to You 📝 Apply Now ❓ Frequently Asked Questions ⚠️ Grievance Portal ⭐ Why Choose Us 📞 Contact Us

📖 Licensing Framework Overview

At the heart of the Virtual Assets Act, 2026 is a requirement that all Virtual Asset Service Providers must obtain a formal licence before offering services in Pakistan. PVARA accepts applications for the Regulatory Sandbox, No Objection Certificates and VASP Licences.

This licensing framework ensures that only legitimate, qualified and accountable companies operate in the virtual-asset market, protecting consumers and maintaining market integrity.

Licensees must follow strict operational and security standards — safeguarding customer funds, maintaining robust cybersecurity, providing clear disclosures and ensuring transparent business practices.

Official PVARA Support Contact: licensing@pvara.gov.pk — for licensing inquiries.

How to Apply

✔ Regulatory Sandbox

✔ No Objection Certificate (NOC)

✔ VASP Licence

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🗂️ Types of Licences

The Virtual Assets Act, 2026 sets out the Licence Categories below in Schedule I. An applicant may apply for one or more of them.

Advisory Services

Advising on virtual assets, including investment advice, portfolio composition and the merits of particular virtual assets.

Broker-Dealer Services

Receiving and transmitting orders, and dealing in virtual assets on own account or on behalf of clients.

Custody Services

Safekeeping, holding or controlling virtual assets, or the means of access to them, on behalf of clients.

Exchange Services

Operating a platform for the exchange of virtual assets for fiat currency or for other virtual assets.

Lending and Borrowing Services

Facilitating the lending or borrowing of virtual assets between clients or on own account.

Virtual Asset Derivatives Services

Dealing in, arranging or operating a platform for derivatives referencing virtual assets.

Virtual Asset Management & Investment Services

Managing virtual assets or portfolios of virtual assets on a discretionary basis on behalf of clients.

Virtual Asset Transfer & Settlement Services

Transferring virtual assets between addresses or accounts, and providing settlement of such transfers.

Asset-Referenced Token Issuance Services

Issuing tokens that purport to maintain a stable value by reference to another asset, basket or right.

Fiat-Referenced Token Issuance Services

Issuing tokens that purport to maintain a stable value by reference to a single fiat currency.

Mining Related Virtual Asset Services

Providing mining, validation or related infrastructure services in respect of virtual assets.

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✅ Licensing Requirements

Applicants will need to meet the following requirements to obtain a VASP licence when full licensing becomes available.

Legal Entity Registration

Applicant must be a company registered in Pakistan under the Companies Act 2017.

Minimum Capital Requirements

Meet prescribed minimum paid-up capital requirements based on licence category.

Fit and Proper Test

Directors and key personnel must pass fit and proper criteria including background checks.

AML/CFT Compliance Program

Establish comprehensive KYC, transaction monitoring and suspicious activity reporting systems.

Cybersecurity Framework

Implement robust cybersecurity measures to protect customer assets and data.

Business Continuity Plan

Maintain disaster recovery and business continuity arrangements.

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🛤️ Your Path to Licensing

Choose your path based on the regulatory requirement and your assessment.

TRACK A

Sandbox to Licence

For firms testing an innovative product under supervision before seeking a Licence.

Sandbox Application: Apply to test an innovative virtual-asset product under supervision.
Admission to the Sandbox: Test within the agreed scope, duration and customer limits.
Controlled Testing: Meet the reporting, safeguarding and disclosure requirements throughout the test.
Sandbox Exit: Complete the test and satisfy the exit criteria.
VASP Licence: Apply for a Licence following a successful sandbox exit.

TRACK B

NOC to Licence

For firms incorporating a licensed entity in Pakistan. Transitional Persons — operating since 5 March 2026 or before — must submit an NOC application by 5 September 2026, or cease operations, as required under Section 70 of the Virtual Assets Act, 2026.

Application for NOC: Submit business plan and corporate documents for No Objection Certificate.
Issuance of NOC: Receive preliminary approval and authorization to proceed.
Regulatory Compliances: Complete registration with the Financial Monitoring Unit and the applicable regulatory requirements.
Local Incorporation: Establish subsidiary company under Companies Act 2017.
VASP Licence: Submit the licensing application following incorporation.

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🧭 Which Route Applies to You

Submit and track applications online. You will need an applicant account, and can save a draft and return at any time. Final decision on the Application Route is with the applicant.

You hold an NOC under the NOC Regulations, 2025

Then submit: A Licence application under regulation 7. No fresh NOC is required.

By when: 3 months from the date of promulgation of the Licensing Regulations.

You were providing Virtual Asset Services in or from Pakistan, by way of business, on or before 5 March 2026

Then submit: Form I. A complete Form I preserves your right to continue operating pending determination.

By when: 5 September 2026, as specified in Section 70 of the Virtual Assets Act, 2026.

Neither of the above, and you intend to carry on Virtual Asset Activity

Then submit: A Regulatory Sandbox application under the Sandbox Guidelines, or an NOC application under the Services Regulations.

By when: Open — apply when ready.

⚠️ Important

You should only apply for Licensing if you hold an NOC from PVARA. Otherwise, submit an NOC or Sandbox application as per your route.

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📝 Apply Now

The PVARA application portal is open for the Regulatory Sandbox, No Objection Certificates and VASP Licences. Please go through the PVARA Services Regulations, PVARA Activity Specific Regulations and Sandbox Guidelines, then choose the path based on your assessment and regulatory requirements.

Regulatory Sandbox Application

Test an innovative virtual-asset product under supervision. Read the guidelines and apply.

No Objection Certificate (NOC) Application

For firms incorporating a licensed entity in Pakistan and Transitional Persons required to file by 5 September 2026.

VASP Licence Application

Submit your licensing application following successful NOC issuance and local incorporation.

Already applied? Track your application through the PVARA portal, or use the Grievance Portal to report concerns. Chamber 92 assists with every stage of the PVARA application process.

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❓ Frequently Asked Questions

On the Pakistan Virtual Asset Services Regulations, 2026 and the Pakistan Virtual Asset Services Activity Specific Regulations, 2026. Not legal advice; the Act and Regulations prevail over anything stated here.

A. The Framework: What Has Been Made and Why

1. What has PVARA published?

PVARA has published the Pakistan Virtual Asset Services Regulations, 2026, the Pakistan Virtual Asset Services Activity Specific Regulations, 2026 and the Sandbox Guidelines, along with advisories on virtual asset-related announcements and activities.

2. When do the Regulations come into force?

The Regulations come into force on their promulgation date. Transitional Persons operating since 5 March 2026 or before must comply with the NOC filing deadline of 5 September 2026 under Section 70 of the Virtual Assets Act, 2026.

3. Does PVARA approve, endorse or guarantee any virtual asset?

No. PVARA does not approve, endorse or guarantee any virtual asset. Licensing is granted to VASPs, not to virtual assets themselves.

4. How can I check whether a firm is licensed?

You can verify licensing status through the PVARA public register and by checking the PVARA portal. Chamber 92 can also assist in verifying counterparties before you transact.

B. Who Needs a License: The Regulatory Perimeter

5. Who must be licensed?

All Virtual Asset Service Providers offering services in or from Pakistan must obtain a formal licence before operating. This includes exchanges, custodians, broker-dealers, advisory, lending, derivatives, token issuers and mining-related services.

6. I operate from outside Pakistan. Which regulations apply to me?

If you provide virtual asset services in or from Pakistan by way of business, the Virtual Assets Act, 2026 and PVARA Regulations apply — even if your entity is incorporated abroad. Local incorporation is required as part of the licensing pathway.

7. Does one Licence Category let me carry on activities in another category?

No. Each licence category authorizes only the activities specified in Schedule I. An applicant may apply for one or more categories, but must be licensed for each activity it carries on.

8. What about activities that are merely ancillary to my licensed service?

Ancillary activities that are necessary for the delivery of the licensed service may be permitted, provided they fall within the scope of the licence and PVARA requirements. We advise clients on the perimeter of permitted ancillary activities.

9. Is virtual asset mining a licensed activity?

Yes. Mining Related Virtual Asset Services — including providing mining, validation or related infrastructure services — is a licensed activity category under Schedule I.

C. License Categories, Capital and Prudential Requirements

10. What License Categories are available?

The categories include Advisory Services, Broker-Dealer Services, Custody Services, Exchange Services, Lending and Borrowing Services, Virtual Asset Derivatives Services, Virtual Asset Management and Investment Services, Virtual Asset Transfer and Settlement Services, Asset-Referenced Token Issuance Services, Fiat-Referenced Token Issuance Services and Mining Related Virtual Asset Services.

11. What is the minimum paid-up capital for each Category?

Minimum paid-up capital requirements are prescribed by PVARA and vary by licence category. Please contact Chamber 92 or check the latest PVARA Regulations for the current thresholds applicable to your category.

D. How to Apply: NOC, License Application and Timelines

12. What are the steps to getting licensed?

Depending on your route: either (a) Sandbox → exit → VASP Licence, or (b) NOC → regulatory compliances → local incorporation → VASP Licence. Chamber 92 guides clients through every step.

13. How long does the NOC take, and how long is it valid?

Processing timeframes and validity periods are set by PVARA under the Services Regulations. Transitional Persons must file by 5 September 2026 to preserve their right to continue operating pending determination.

14. Does an NOC allow me to start operating?

An NOC is preliminary approval and authorization to proceed with the licensing pathway. It is not a licence. Full operation requires a VASP Licence.

15. How long does the Authority take to decide a licence application?

Decision timelines are prescribed by PVARA. Timelines depend on completeness of the application, adequacy of compliance documentation and any requests for further information.

16. What does the application need to contain?

Applications generally require corporate documents, business plan, ownership and governance details, AML/CFT program, cybersecurity framework, business continuity plan, capital evidence and fit and proper information for directors and key personnel.

17. I am a regulatory sandbox participant. Do I still need an NOC?

Sandbox participants follow Track A. Following a successful sandbox exit, they apply for a VASP Licence. Whether an NOC is separately required depends on your specific circumstances — we advise on a case-by-case basis.

18. I already hold or have applied for an NOC under the NOC Regulations 2025. What happens?

You fall under Route A: submit a Licence application under regulation 7. No fresh NOC is required. The deadline is 3 months from the date of promulgation of the Licensing Regulations.

19. What happens if my application is refused?

If an application is refused, PVARA will provide reasons. Depending on the grounds, remedies may include re-application, rectification of deficiencies or appeal as provided under the Act and Regulations. We advise on the most appropriate course.

20. Once licensed, is there a deadline to start operating?

PVARA prescribes operational commencement deadlines and ongoing obligations. Licensees must meet operational, security and reporting standards on an ongoing basis.

21. Can a company with 100% foreign shareholding for the purposes of providing Virtual Asset Services be incorporated?

Foreign participation is permitted subject to applicable foreign exchange, SECP and PVARA requirements. The licensing pathway requires local incorporation as a company under the Companies Act, 2017. Chamber 92 advises on the optimal structure.

E. Governance, Fit and Proper, and Key Individuals

22. Do director and CEO appointments need prior approval?

Yes. Directors, controllers and key individuals are subject to fit and proper assessment. Prior approval requirements are set by PVARA. We prepare and file the necessary applications.

23. How long does approval of a director or Controller take?

Approval timelines depend on the completeness of the submission and PVARA’s review. We follow up actively to minimize delays.

24. What is required of the Board?

The Board must meet governance, independence, competency and fit and proper requirements prescribed by PVARA, and is responsible for oversight of compliance, risk management, AML/CFT and cybersecurity frameworks.

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⚠️ Grievance Portal

Report concerns about Virtual Asset Service Providers, suspected fraud or regulatory violations. PVARA is committed to protecting consumers and maintaining market integrity. Chamber 92 assists clients in preparing and filing complaints and in following up on their status.

Types of Complaints

Suspected Fraud

Report suspected fraudulent activities, scams or deceptive practices by virtual asset service providers.

Unlicensed VASP

Report entities operating virtual asset services without proper PVARA licensing or authorization.

Service Provider Misconduct

Report unprofessional conduct, poor service or violations of consumer rights by licensed VASPs.

Other Grievances

Report any other concerns related to virtual assets or regulatory matters not covered above.

Grievance FAQ

How long does it take to process a complaint?

Initial acknowledgment is sent within 2 business days. Full investigation may take 30–60 days depending on complexity.

Is my complaint confidential?

Yes, all complaints are treated with strict confidentiality. Your personal information is protected under data privacy laws.

Can I track my complaint status?

Yes, you will receive a complaint reference number that can be used to track the status of your complaint.

What if I need to provide additional information?

Our team may contact you via email or phone if additional information is required for the investigation.

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⭐ Why Choose Chamber 92?

PVARA Application Specialists

Complete assistance with Sandbox, NOC and VASP Licence applications under the Virtual Assets Act, 2026.

Transitional Person Support

Urgent NOC filing support for entities operating since 5 March 2026 or before — deadline 5 September 2026.

Corporate Setup

Local incorporation under the Companies Act, 2017 as required for the licensing pathway.

AML/CFT & Compliance

Design and implementation of KYC, transaction monitoring and suspicious activity reporting programs.

Cybersecurity & BCP

Advisory on cybersecurity frameworks and business continuity arrangements required for licensing.

Ongoing Regulatory Advisory

Post-licence compliance, reporting obligations, grievance handling and enforcement defence.

📞 Contact Chamber 92

For expert legal assistance with VASP licensing, PVARA applications and virtual asset regulatory compliance in Pakistan, contact Advocate Qamar Maqsood at Chamber 92.